New Filing Instructions Guide (FIG) 2017/18 Is Out

http://www.consumerfinance.gov/data-research/hmda/for-filers

Thanks Kathleen!

I am disappointed in two things (have not yet reviewed the entire guide):

Even though the CFPB said that the rate spread rounding would not be increased to 3 decimal places from the current 2, they had showed 5 decimal places in the file specs. I inquired about the discrepancy and was told it would be answered in this guide. Well, the guide shows 3 so it did increase.

Also, for reporting the full loan amount the rule says not to round but the examples show loans without "cents". I inquired and again was told it would be addressed in the "FIG". Well, it is no answered so I inquired again today.

I think the FIG will be helpful, but any chance we will get a real GIR (Getting it Right) guide???

I do not know but doubt it. They have tried to gather all instructions (that continue to be pertinent) from the GIR, Appendix A and Q and A into the rule and commentary. I was surprised they planned a FIG.

There is one new piece of information in the FIG. Sex has a new code 6, applicant selected both male and female. This is not covered in the commentary and they may not deem it as needing explanation. It would on the face of it be used whenever both were selected, whether in error or intentionally.

I just read through the 2018 FIG, and it is amazing to me how inconsistent the reporting requirements are between data points.

For some data points, if the field doesn't apply to the loan, you might have to report "NA", some require a code that means "NA", or some just leave the field blank.

Rounding is going to be another issue, as certain fields are rounded to two places, three places, or for DTI and LTV, it depends on how your institution rounds the field in their decision making (rounded to the nearest whole percentage or not), and other fields don't specify how rounding should occur (loan amount).

The actual data points aren't going to be the hardest part of this regulation. It all this technical BS that is going to trip people up. Why not round all dollar or percentage fields to two places and require "NA" for all fields that aren't applicable.

::rant over::

I have to agree about the rounding and the NA reporting. The NA reporting is all over the place.

I wonder if the inconsistencies are results of the fact that although the Bureau is now the rulemaker for Regulation C, the FFIEC created (with HUD?) the FIG.

I felt that the CFPB's "Small Entity Compliance Guide" was more useful than the FIG. Just my opinion.

The two documents have different purposes. The FIG is really the new "file specs".

I wanted to add that further reading shows that you must report at least three decimals for rate spread and can report more than three.

[Bangs head against desk]

Does going to the thousandth decimal place really add any value to the data? This is just asinine.